DSHW-2013-002596 - 0901a068803619dd

State of Utah
GARY HERBERT
Governor
GREG BELL
Lieutenant Goverrtor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
MEMORANDI]M
ATK Launch Systems - Promontory File
Brad Maulding 6CfA
Section Manager
Hazardous Waste Facilities Section
Division of Solid and Hazardous Waste
Jeff Vandel f, /
Environmental Scientist
Hazardous Waste Facilities Section
Division of Solid and Hazardous Waste
Identified Issues from the 2011 Operation & Maintenance Inspection, the
2012 Compliance Evaluation Inspection and the 2011 ATK Storm Water
Management Plan
March 26,2013
TO:
THROUGH:
FROM:
SUBJECT:
DATE:
This memo concems three primary issues that the Division has been working on with ATK
Launch Systems - Promontory. These issues all revolve around one central question - are current
operations at the M-136 Burn Grounds contributing to the rising perchlorate concentrations that
have been observed in wells C-1 and D-4?
The three issues originally arose from three different documents/inspections and are described
below:
l. The Division first requested that ATK conduct a statistical trend test for a number of wells
in the M-136 Burn Grounds area in the December, 2011 letter to ATK regarding the results
of the O&M Inspection. ATK has collected more data since that time and has submitted
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Printed on 10070 recYcled PaPerDSHW-2013-002596
the results of the statistics. A rising concentration trend was confirmed for wells C-l and
D-4.
2. In the letter following our compliance evaluation inspection of ATK Promontory in
September, 2012, the Division discussed the management of ash at the burn grounds and
requested that ATK begin disposing their ash off-site. This request was based on some
analytical results that ATK provided that has questionable value for representing ash that
is disposed on-site.
3. The Division has provided ATK with comments on the Storm Water Management Plan
that was submitted by ATK in April, 2011. The Division has some concerns with ATK's
evaluation of surface water reaching ground water and potentially being a source of
contamination. A response from ATK on the comments is forthcoming.
The Division has requested that ATK submit a plan, for approval, to investigate potential sources
of perchlorate contamination at the M-136 Burn Grounds (letter to Robert Ingersoll, ATK is dated
March 14,2013). The Division has requested that ATK combine the three issues into the
investigation plan in an effort to answer the central question - are current operations at the M-136
Bum Grounds contributing to the rising perchlorate concentrations in groundwater? It is
estimated that the plan should be submitted to the Division by the end of May.
DSHW-2013-002596